Jurisdiction: United Arab Emirates · Published and reviewed: 20 October 2026
The Ministry of Finance announced Ministerial Decision No. 197 of 2026 on 19 October. It amends Decision No. 243 of 2025 and took effect on 1 October 2026.
Three changes to check
- Same-tax-group transactions: business transactions between members of the same Tax Group are excluded for 24 months starting 1 January 2027. This is not a blanket exclusion for every transaction between related businesses.
- Record storage: the requirement to store electronic invoices, electronic credit notes and associated data within the UAE is removed. Retention for the period required by the Tax Procedures Law and availability to the FTA on request remain necessary.
- System failure: Article 12 and the related definition are removed, including the two-business-day FTA notification requirement under Decision No. 243. This does not establish that every other contractual or regulatory reporting obligation has ended.
A practical review for your finance team
The following checks are our suggested working approach, not extra statutory requirements:
- Map transactions before changing settings. List the entities, counterparties and invoice flows in your accounting system. Have the appropriate adviser confirm which flows actually satisfy the Tax Group condition; shared ownership alone should not be your classification evidence.
- Test retrieval, not just storage. Ask your software provider to demonstrate a complete invoice and credit-note export with its associated data. Record who can retrieve it when your usual finance contact is unavailable.
- Keep an incident procedure. Review your provider contract and internal escalation process before removing any notification task. Keep an owner for failed transmissions, corrections and unresolved exceptions.
- Document the decision. Keep the reviewed source, your transaction mapping and the person responsible for any system change together. This makes a later handover easier to follow.
For example, a group with both internal charges and sales to outside customers should review those flows separately. One accounting-system switch applied to all customers could obscure an important distinction.
Read alongside the provider rules
This update concerns the business-side requirements above. Our separate UAE e-invoicing provider-accreditation update covers the provider framework. Use both when preparing questions for your provider; do not treat this summary as a replacement for your implementation plan.
Official source and support
Ministry of Finance announcement, 19 October 2026. Check the current decision and official guidance against your circumstances.
To discuss the records and accounting workflows behind your review, see our UAE VAT services, monthly bookkeeping support or request a consultation. Any technical integration or other work needs a separately agreed scope.
General information reviewed on 20 October 2026. The practical review is editorial guidance, not individual tax advice.
